Protected health information (PHI)

Priority Health protects the privacy of current and former member protected health information (PHI) from unauthorized or inappropriate use in all settings to meet all federal, state and/or local laws and regulations and accreditation requirements. Employees of Priority Health, providers, practitioners, employers and organizations that provide services to Priority Health are informed of this obligation to protect the privacy of member information.

Priority Health requires that all agents sign a business associate agreement (BAA) to maintain the confidentiality of all member information. The BAA is Attachment C of the agent agreement (907KB PDF).

Definition of protected health information (PHI)

Protected health information (PHI) is any individually identifiable information created or received by a health care provider, health plan, employer, or health care clearinghouse, that relates to past, present, or future physical or mental health of the individual, provision of care to this individual, or payment for his or her care. PHI includes, but is not limited to:

• Member personal and demographic information
• Medical records
• Reports, data, and claims information relating to diagnosis, prognosis and treatment for physical and mental illness, mental health, substance abuse, communicable diseases, serious communicable diseases and infections, and other conditions, ailments, sicknesses and diseases, including human immunodeficiency virus (HIV) infection and acquired immunodeficiency syndrome (AIDS)

Note: HIPAA authorizations (download the English and Spanish versions) are needed in some situations for the release of information regarding mental health issues, substance abuse issues and HIV/AIDS, or for grievances/appeals.

Examples of PHI

All of the following identifiers of individuals (including relatives, employers or household members of an individual) are considered to be PHI and must be protected:

• Names
• All geographic subdivisions smaller than a state, including street address, city, county, precinct, ZIP code, and their equivalent geo-codes, except for the initial three digits of a ZIP code if, according to the current publicly available data from the Bureau of the Census:
  • The geographic unit formed by combining all ZIP codes with the same three initial digits contains more than 20,000 people; and
  • The initial three digits of a ZIP code for all such geographic units containing 20,000 or fewer people are changed to 000.
• All elements of dates (except year) for dates directly related to an individual, including birth date, admission date, discharge date, date of death; and all ages over 89 and all elements of dates (including year) indicative of such age, except that such ages and elements may be aggregated into a single category of age 90 or older
• Telephone numbers
• Fax numbers
• Electronic mail addresses
• Social Security numbers
• Medical record numbers
• Health plan beneficiary numbers
• Account numbers
• Certificate/license numbers
• Vehicle identifiers and serial numbers, including license plate numbers
• Device identifiers and serial numbers
• Web Universal Resource Locators (URLs)
• Internet Protocol (IP) address numbers
• Biometric identifiers, including finger and voice prints
• Full face photographic images and any comparable images
• Any other unique identifying number, characteristic, or code